IX. Time and Effort Reporting - Grants and Sponsored Projects

IX. Time and Effort Reporting

Lesley's policy is to comply with all applicable federal
regulations and guidance regarding time and effort reporting to
ensure good stewardship of the funds provided to the University for
grants and sponsored projects. The University's effort distribution
system and certification reporting system requires that all effort
directly associated with a sponsored program be classified
consistently, regardless of whether the salary is charged to the
sponsor or to the cost shared by the University.

As a condition of receiving funding from the federal government,
the University is required to maintain and certify the percentage
of effort employees devote to externally-sponsored projects. The
University's effort reporting system is an after-the-fact system
requiring the completion of an Effort Reporting form (see
below).

Faculty and staff are expected to commit some level of effort
(i.e., greater than 0%) on proposals in which they are listed as
Principal Investigator, or key personnel. Since these roles assume
responsibility for the scientific, administrative, and financial
management of an award, it is assumed that fulfilling these
responsibilities requires time and effort. However, there are
instances in which certain types of proposals do not require
individuals to commit any level of effort. These exceptions include
equipment and instrumentation grants, student augmentation grants,
and faculty training grants.

Faculty and professional staff shall complete an Effort
Reporting Form near the end of each academic term. Hourly staff
shall complete bi-weekly time sheets to certify their effort.

WHAT IS EFFORT?

An individual's effort is defined as the percentage of time
spent on a particular work-related activity, such as instruction,
research, advising, administration, etc., for which the individual
is compensated by the University.

WHAT IS EFFORT REPORTING?

White House Office of Management and Budget (OMB) federal
regulation OMB Circular A21 requires that Lesley
University certify the effort for each employee who expended effort
on a federally-sponsored project. Incomplete or improper reporting
of effort is a compliance violation that could result in audit
disallowances and/or withholding of federal research funding.

The percentage of effort on an Effort Report
should be consistent with commitments made by the individual to the
sponsor. The Effort Report also compares the percent of
effort spent on a project and the percent of
salary charged to that project. The percent of
effort spent on a federally-sponsored project should not
be less than the percent of salary charged to the
project.

The report shall reasonably reflect the percentage distribution
of time and effort expended by faculty and professional staff
involved in externally-sponsored projects.

The report shall be completed and signed by each faculty and
professional staff working on an externally-sponsored project.
Faculty and staff must document the time and effort spent on the
project regardless of whether the sponsor pays for the time or the
time is cost-shared by LU.

The report shall be confirmed by a person having firsthand
knowledge of the employee's activities. Confirmation is indicated
by a countersignature on the form.

The report shall not be completed for employees who submit time
sheets.

Failure to submit the Time and Effort Certification Form may
result in the suspension of grant activity.

EFFORT REPORTING SCHEDULE

Effort reports are generated on a semi-annual and quarterly
schedule, depending on an individual's classification. The below
text shows the six (6) Reporting Periods for the year (2) for
Academics and (4) for non-Academics:

All faculty receive Effort Reports on a
semi-annual Academic schedule for the
following periods:

Academic Spring: January-June

Academic Fall: July-December

All other staff receive Effort Reports on
a quarterly Non-Academic schedule for the
following periods:

Non-Academic Winter: January-March

Non-Academic Spring: April-June

Non-Academic Summer: July-September

Non-Academic Fall: October-December

EFFORT REPORTING CYCLES AND DATES

There are four effort reporting cycles a year. The below chart
details which Effort Reports are included in each cycle, the
deadline for reports to be issues, and certification deadlines.

Reporting Cycle

End Date

Effort Reports included
in cycle

Issuance Deadline

(45 days)

Certification Deadline

(30 days)

March 31

Non-Academics

May 15

June 14

June 30

Academics +
Non-Academics

August 14

September 13

September 30

Non-Academics

November 14

December 14

December 31

Academics +
Non-Academics

February 14

*March 16/17

*depending on Leap Year

EFFORT REPORTING POLICY

Each school's budget officer shall maintain the
University-approved system of after-the-fact confirmation to
substantiate salary costs that are directly charged to federally
funded projects consistent with the following standards:

Certification of Effort by Principal Investigators and
Other Faculty in Professorial, Professional Research, and
Management Titles Principal Investigators and other faculty in
Professorial, Professional Research, and Management titles who are
paid on federal on federal flow-through funds are required to
certify their own effort since they are in the best position to
understand how they are spending their time in support of the
various activities in which they are engaged. This is consistent
with the OMB Circular A-21 requirement that the distribution of
salaries and wages be supported by activity reports that are
confirmed by "a responsible person with suitable means of
verification that the work was performed."
Note: PIs and other professionals must certify their own reports.
Academics such as post-docs and students were not intended to be
included in this group- their effort can be certified by someone
with first-hand knowledge of the work performed. Staff are not
asked to certify their own effort.

Treatment of Effort Reporting Revisions Changes to previously certified Effort Reports should be
extremely rare. However, if an effort report is determined to be in
error, a new one can be prepared coincident with payroll cost
transfers and other extenuating circumstances. Such revisions are
subject to a "facts and circumstances" review and must be processed
on a timely basis consistent with federal regulations and
University policy (within 120 days of incurring the costs) to
ensure their allowability under audit. If revisions are required
after 120 days, the extremely unusual extenuating circumstances
surrounding the need for a corrected effort report must be fully
explained and documented.

Timeliness of Certifications Effort Reports should be issued for certification by a
center, department, or OGSP no more than 45 days after the close of
the reporting period and certified within 30 days of their issuance
to ensure that federal compliance expectations are met.

Preciseness of Certifications OMB Circular A-21 provides for "a degree of tolerance" in
the preciseness of effort reporting. A precise assessment of
factors that contribute to costs is not always feasible, nor is it
expected. An individual at Lesley may thus certify a level of
effort for an award or activity that is within +/- 5% of their best
estimate of the actual effort expended during the reporting
period.

Allowability of Supplemental Compensation Federal rules and regulations, including OMB Circular
A-21, do not allow for an individual's institutional base salary to
be increased as a result of obtaining grant funding. These federal
rules and regulations also restrict the payment of overload, bonus
or other payments outside the individual's institutional base
salary. In addition to the University's general policy regarding
the allowability of supplemental compensation, the following
principles must be applied when salary is to be paid from a
sponsored project. Charges for work performed on sponsored
agreements by faculty members must be based on the individual
faculty member's regular compensation during the period of
performance. The only exception to allow for compensation above the
base salary during the academic year is a very specific exception
for consultation across departmental lines.

The general rules for faculty compensation during the academic
year and the specific requirement for the exception to those rules
are found in OMB Circular Act 21, section J.10.d and are as
follows:

Salary rates for academic year. Charges for work performed on
sponsored agreements by faculty members during the academic year
will be based on the individual faculty member's regular
compensation for the continuous period which, under the policy of
the institution concerned, constitutes the basis of his salary.
Charges for work performed on sponsored agreements during all or
any portion of such period are allowable at the base salary rate.
In no event will charges to sponsored agreements, irrespective of
the basis of computation, exceed the proportionate share of the
base salary for that period. This principle applies to all members
of the faculty at an institution.

Since intra university consulting is assumed to be undertaken as a
university obligation requiring no compensation in addition to full
time base salary, the principle also applies to faculty members who
function as consultants or otherwise contribute to a sponsored
agreement conducted by another faculty member of the same
institution. However, in unusual cases where consultation is across
departmental lines or involves a separate or remote operation, and
the work performed by the consultant is in addition to his regular
departmental load, any charges for such work representing extra
compensation above the base salary are allowable provided that such
consulting arrangements are specifically provided for in the
agreement or approved in writing by the sponsoring agency.

These rules are no applicable to summer salary for nine (9) month
faculty. See OMB circular A-21 J.10.d (2)(a). Research compensation
during the summer months or other periods not included in the base
salary period is to be calculated for each faculty member at a rate
not in excess of the base salary divided by the period to which the
base salary relates.